OIG Won’t Impose Sanctions on Hospital-Physician Arrangement
Jan. 9 — The Office of Inspector General (OIG) will not impose sanctions on a
specific compensation arrangement that a large, rural acute care
hospital has with a cardiology group, the OIG said in a new advisory opinion.
The three-year co-management arrangement includes the physician group
receiving a performance bonus for implementing certain measures related
to patient service, quality, and cost savings associated with procedures
performed at the hospital’s cardiac catheterization laboratories.
The OIG concluded that the arrangement contains sufficient
safeguards, such as fixed-fee, employee satisfaction, patient
satisfaction, and quality components that do not involve an inducement
to reduce or limit services. Therefore, the arrangement does not
implicate the Civil Monetary Penalty of the Social Security Act and
poses a low risk of fraud or abuse under the federal anti-kickback
The hospital, located in a medically underserved area, operates four
cardiac catheterization laboratories on its main campus; six of the
physician group’s interventional cardiologists perform procedures in
these labs. The cardiology group is the only such group on the
hospital’s medical staff and the only physician group in town that
provides cardiac catheterization services.
HFMA Analysis: Co-management is a strategy more
organizations are considering to align economic incentives between
physicians and hospitals in order to improve the quality and reduce the
cost of care for patients. The OIG’s analysis provides a great example
of how the incentives for these types of arrangements can be structured
to facilitate the goal of value improvement.
Publication Date: Wednesday, January 09, 2013